The U.S. Department of Health & Human Services (HHS) has announced that an analysis of 2024 enrollment data revealed 2.8 million Americans who are enrolled in Medicaid or the Children’s Health Insurance Program (CHIP) in more than one state, or who are enrolled in Medicaid/CHIP while also being enrolled in a subsidized Affordable Care Act (ACA) exchange plan. And the Centers for Medicare & Medicaid Services (CMS) is restarting the process of checking for redundant enrollments.
In a July 17 press release, HHS said CMS “is taking action to ensure individuals are only enrolled in one program and to stop the federal government from paying multiple times for these individuals to receive health coverage.”
While there are federal regulations in place to require exchanges to periodically check for dual enrollments in Medicaid, the process was paused under the Biden administration “to ensure that continuous coverage was maintained during the PHE [public health emergency], in alignment with the statutory requirement on states to maintain continuous enrollment in Medicaid or CHIP throughout the COVID public health emergency,” the press release said.
HHS said eliminating duplicate enrollments could save taxpayers “approximately $14 billion annually” because data showed that in 2024, an average of 1.2 million Americans were enrolled in Medicaid or CHIP in multiple states, while an average of 1.6 million Americans monthly were enrolled simultaneously in Medicaid or CHIP and a subsidized exchange plan.
“HHS staff uncovered millions of Americans who were illegally or improperly enrolled in Medicaid and ACA plans,” said HHS Secretary Robert F. Kennedy Jr. “Under the Trump Administration, we will no longer tolerate waste, fraud and abuse at the expense of our most vulnerable citizens. With the passage of the One Big Beautiful Bill, we now have the tools to strengthen these vital programs for generations to come.”
HHS said CMS will work with states to implement three initiatives:
— CMS will provide states with lists of patients enrolled in Medicaid or CHIP in two or more states and ask states to check those patients’ eligibility. “CMS will work with states to prevent individuals from losing coverage inappropriately,” the press release said.
— Patients enrolled in Medicaid or CHIP while also enrolled in a subsidized federally facilitated exchange (FFE) plan have been notified by CMS and will be required to withdraw from Medicaid or CHIP if they’re no longer eligible; or end their subsidy, with the option to end their coverage; or notify the exchange and provide documentation to demonstrate that they are not improperly enrolled.
“After 30 days, the FFE will end the subsidy for individuals who still appear to be enrolled in both Medicaid or CHIP and an exchange plan with a subsidy,” HHS said.
— CMS will provide subsidized state-based exchange plans (SBEs) with lists of patients that the agency believes are enrolled in Medicaid/CHIP and an SBE simultaneously. If the SBEs determine that patients are improperly enrolled, the SBEs will be told “to implement a process, similar to the federal exchange, to recheck eligibility. CMS will work with states to prevent individuals from losing coverage inappropriately.”
In August, CMS will provide Medicaid and CHIP programs additional information on “expectations for tackling concurrent enrollment. The agency will follow up with lists to each state of individuals concurrently enrolled in Medicaid or CHIP and ask states to make their best efforts to recheck eligibility by late fall.”
“Going forward,” HHS added, “CMS will continue to work with states to provide support for their existing Medicaid/CHIP and exchange data matching processes and work to implement new requirements in the One Big Beautiful Bill Act designed to eliminate and prevent duplicate enrollment in Medicaid programs.”
